United States Office of Special Counsel

For the other United States offices of special counsel, see U.S. Office of Special Counsel (disambiguation).

United States Office of Special Counsel
Official seal
Agency overview
Formed	January 1, 1979
Jurisdiction	Federal government of the United States
Headquarters	1730 M Street, NW Washington, D.C.
Employees	103 (2010)
Annual budget	US$18.495 million (2010)
Agency executive	Carolyn N. Lerner, Special Counsel
Website
osc.gov

The United States Office of Special Counsel (OSC) is a permanent independent federal investigative and prosecutorial agency whose basic legislative authority comes from three federal statutes, the Civil Service Reform Act, the Whistleblower Protection Act and the Hatch Act. Its primary mission is to protect federal employees and others from "prohibited personnel practices," including the deliberate targeting of whistleblowers for punishment. The Special Counsel also accepts disclosures of wrongdoing, and coordinates the federal Government's response to the identification of wrongdoing. Also within the Special Counsel's jurisdiction is Hatch Act enforcement, namely the regulation of unlawful partisan political activities by federal employees. OSC has around 100 staff,^[1] and the Special Counsel is an ex officio member of Council of Inspectors General on Integrity and Efficiency (CIGIE), an association of Inspectors General charged with the regulation of good governance within the federal government. The agency attracted public attention in April 2007 when it began an investigation of alleged White House political pressure on federal civil servants. Senior Bush political adviser Karl Rove was reported to be a subject of the investigation.^[2]

Jurisdiction

Pursuant to 5 U.S.C. § 1214, the U.S. Office of Special Counsel (OSC) has jurisdiction over prohibited personnel practices committed against most employees or applicants for employment in Executive Branch agencies including the Department of Defense. Current and former federal employees and applicants for federal employment may report suspected prohibited personnel practices to the OSC. The matter will be investigated, and if there is sufficient evidence to prove a violation, the OSC can seek corrective action, disciplinary action, or both. OSC has determined that a federal employee or applicant for employment engages in whistleblowing when the individual discloses to the Special Counsel or an Inspector General or comparable agency official (or to others, except when disclosure is barred by law, or by Executive Order to avoid harm to the national defense or foreign affairs) information which the individual reasonably believes evidences the following types of wrongdoing: a violation of law, rule, or regulation; or gross mismanagement, a gross waste of funds, an abuse of authority, or a substantial and specific danger to public health or safety.^[3] While OSC has broad jurisdiction, it has no jurisdiction over prohibited personnel practices (including reprisal for whistleblowing) committed against employees of the Central Intelligence Agency, Defense Intelligence Agency, National Security Agency, and certain other intelligence agencies excluded by the President, (see 5 U.S.C. §2302(a)(2)(C)(ii)).

OSC was established on January 1, 1979. From then until 1989, the office operated as the independent investigative and prosecutorial arm of the Merit Systems Protection Board (MSPB, or “the Board”). By law, OSC received and investigated complaints from current and former federal employees, and applicants for federal employment, alleging prohibited personnel practices by federal agencies; enforced the Hatch Act, including by advice on restrictions imposed by the act on political activity by covered federal, state, and local government employees; and received disclosures from federal whistleblowers (current and former employees, and applicants for federal employment) about wrongdoing in government agencies. The office enforced restrictions against prohibited personnel practices andpolitical activity by filing, where appropriate, petitions for corrective and/or disciplinary action with the Board.

In 1989, Congress enacted the Whistleblower Protection Act (WPA). The statute made OSC an independent agency within the executive branch of the federal government, with continued responsibility for the functions described above. It also strengthened protections against reprisal for employees who disclose wrongdoing in the government, and enhanced OSC’s ability to enforce those protections.

Congress enacted legislation in 1993 that significantly amended Hatch Act provisions applicable to federal and District of Columbia (D.C.) government employees, and enforced by OSC. (Provisions of the act enforced by OSC with respect to certain state and local government employees were unaffected by the 1993 amendments.)

In 1994, the Uniformed Services Employment and Reemployment Rights Act (USERRA) became law. It defined employment-related rights of persons in connection with military service, prohibited discrimination against them because of that service, and gave OSC new authority to pursue remedies for violations by federal agencies.

Also in 1994, OSC’s reauthorization act expanded protections for federal employees, and defined new responsibilities for OSC and other federal agencies. It provided, for example, that within 240 days after receiving a prohibited personnel practice complaint, OSC should determine whether there are reasonable grounds to believe that such a violation occurred, exists, or is to be taken. The act extended the protections of certain legal provisions enforced by OSC to approximately 60,000 employees of what is now the Department of Veterans Affairs (DVA), and to employees of certain government corporations. It also broadened the scope of personnel actions covered under those provisions. Finally, the act made federal agencies responsible for informing their employees of available rights and remedies under the WPA, and directed agencies to consult with OSC in that process.

In November 2001, Congress enacted the Aviation and Transportation Security Act,6 creating the Transportation Security Administration (TSA). Under the act, non-security screener employees of TSA can file allegations of reprisal for whistleblowing with OSC and the MSPB. Approximately 45,000 security screeners in TSA, however, could not pursue such complaints at OSC or the Board. OSC efforts led to the signing of a memorandum of understanding (MOU) with TSA in May 2002, under which OSC would review whistleblower retaliation complaints from security screeners, and recommend corrective or disciplinary action to TSA, when warranted.

Prohibited personnel practices

The 1978 Civil Service Reform Act created the Office of Special Counsel (OSC), an office mandated to protect whistleblowers from reprisal and prosecute managers for retaliation. Under former President Carter the Office languished with no permanent head, funding, or White House support. The OSC nevertheless held its own through major bureaucratic turf wars. When Ronald Reagan came to power he quickly gutted the Office of Special Counsel. Within 14 months of the appointment of Special Counsel Alex Kozinski to head the OSC, nearly half of the office personnel and 70 percent of attorneys and investigators at the office's headquarters were fired or had resigned. No other agency in government was purged as quickly or completely. Since that time, 7,000 federal employees have sought assistance from the OSC. The OSC has filed for a hearing to restore jobs on only two occasions. Every time the OSC has attempted to discipline managers for allegedly discriminating against whistleblowers the prosecutions were thrown out by the MSPB or at the federal court level.^[4]

The Watergate investigation of the previous decade revealed a Nixon administration operation to replace the non-partisan civil service system with a politically loyal workforce dedicated to partisan election goals. Every agency had a shadow “political hiring czar” whose operation trumped normal civil service authority of personnel offices. Then-White House Personnel Office chief Fred Malek teamed up with Alan May to prepare the “Malek Manuel” as an encyclopedic guide for how to harass career employees out of the government by exploiting loopholes in civil service laws. Non-complying federal employees would be replaced by applicants selected through a political rating system of 1-4, based on factors such as campaign contributions and future campaign value. The Watergate Committee’s public record of the abuses led to creation of the Ink Commission, whose exhaustive study and recommendations were the foundation for the Civil Service Reform Act of 1978, including creation of the Office of Special Counsel to see that this type of merit system abuse never happened again.

However, four years later there was another severe attack on the merit system. Ironically, the assailant was then-Special Counsel Alex Kozinski, who kept a copy of the Malek Manuel on his desk. He used its techniques to purge the professional civil service experts on his own staff, and replace them with employees who viewed whistleblowers as crazy troublemakers, disloyal to the President. He taught courses to federal managers on how to fire whistleblowers without getting caught by his own investigators, using the OSC Investigations Manual as a handout. He tutored Secretary Watt on how to purge a whistleblowing coal mine inspector from the Department of Interior. The OSC became what one Senate staffer called “a legalized plumbers unit.” Mr. Kozinski’s abuses were the major catalyst for passage of the Whistleblower Protection Act of 1989, and he was forced to resign. A few years later 43 Senators voted against his confirmation for a seat on the Ninth Circuit Court of Appeals, after Senator Levin’s intensive investigation of Kozinski’s Special Counsel tenure.^[5]

OSC's primary mission is to protect federal employees and others from "prohibited personnel practices". Those practices, defined by law at § 2302(b) of Title 5 of the United States Code (U.S.C.), generally stated, provide that a federal employee authorized to take, direct others to take, recommend or approve any personnel action may not:

1. discriminate against an employee or applicant based on race, color, religion, sex, national origin, age, handicapping condition, marital status, or political affiliation;
2. solicit or consider employment recommendations based on factors other than personal knowledge or records of job-related abilities or characteristics;
3. coerce the political activity of any person;
4. deceive or willfully obstruct anyone from competing for employment;
5. influence anyone to withdraw from competition for any position so as to improve or injure the employment prospects of any other person;
6. give an unauthorized preference or advantage to anyone so as to improve or injure the employment prospects of any particular employee or applicant;
7. engage in nepotism (i.e., hire, promote, or advocate the hiring or promotion of relatives);
8. engage in reprisal for whistleblowing—i.e., take, fail to take, or threaten to take or fail to take a personnel action with respect to any employee or applicant because of any disclosure of information by the employee or applicant that he or she reasonably believes evidences a violation of a law, rule or regulation; gross mismanagement; gross waste of funds; an abuse of authority; or a substantial and specific danger to public health or safety (if such disclosure is not barred by law and such information is not specifically required by Executive Order to be kept secret in the interest of national defense or the conduct of foreign affairs—if so restricted by law or Executive Order, the disclosure is only protected if made to the Special Counsel, the Inspector General, or comparable agency official);
9. take, fail to take, or threaten to take or fail to take a personnel action against an employee or applicant for exercising an appeal, complaint, or grievance right; testifying for or assisting another in exercising such a right; cooperating with or disclosing information to the Special Counsel or to an Inspector General; or refusing to obey an order that would require the individual to violate a law;
10. discriminate based on personal conduct which is not adverse to the on-the-job performance of an employee, applicant, or others; or
11. take or fail to take, recommend, or approve a personnel action if taking or failing to take such an action would violate a veterans’ preference requirement; and
12. take or fail to take a personnel action, if taking or failing to take action would violate any law, rule or regulation implementing or directly concerning merit system principles at 5 U.S.C. § 2301.^[6]

Scott J. Bloch

On June 26, 2003, President George W. Bush nominated Scott J. Bloch for the position of Special Counsel at the Office of Special Counsel; he was confirmed by the U.S. Senate on December 9, 2003. On January 5, 2004, he was sworn in to serve a five-year term.^[7] Bloch has been a lightning rod for controversy since he took the position, his first major actions as head of the office were to choose as deputy a lawyer who had publicly taken a position against the "homosexual agenda," and to hire young lawyers from Ave Maria School of Law, the conservative Catholic school founded by Domino's Pizza billionaire Tom Monaghan.^[8]

On May 6, 2008, news agencies report that the Federal Bureau of Investigation was serving warrants on Special Counsel offices in Washington D.C., and in Texas, seized computers and searched Bloch's home. It was alleged that when Bloch's refusal to follow up on cases of discrimination based on sexual orientation was leaked to the press, he retaliated against career employees by creating a field office in Detroit. It was further alleged that he obstructed the investigation by removing material from his computer.^[9]

Scott Bloch pleaded guilty and is set to be sentenced on September 8, 2010.^[10]

Controversy

The OSC has been criticized for (1) very rarely recognizing legitimate whistleblowers, typically only when the whistleblower has already prevailed elsewhere, (2) taking too long to investigate meritorious cases, (3) using a conservative litmus test in hiring, (4) discouraging federal whistleblowers from using their legal protections, and (5) generally siding with the federal administration instead of with the whistleblowers it is supposed to protect.^[11][12]

On March 22, 2007, U.S. Senator Daniel K. Akaka (Democrat, Hawaii), Chairman of the Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia, held a hearing on "Safeguarding the Merit System Principles." In his opening statement, Sen. Akaka stated, "organizations that help whistleblowers claim that OSC has gone from being their first option for relief to their last choice since OSC no longer works with agencies to achieve informal relief and the percentage of corrective actions and stays has been cut in half since 2002." ^[13]

List acting and confirmed United States Special Counsels

• Carolyn N. Lerner (Apr. 2011 > ). The United States Senate confirmed Carolyn Lerner as the 8th Special Counsel on April 14, 2011.^[14] Ms. Lerner was a partner at the civil rights and employment firm of Heller, Huron, Chertkof, Lerner, Simon & Salzman. She was recognized by Best Lawyers in America and was one of Washingtonian Magazine's top employment lawyers. At George Washington University Law School she served as adjunct faculty, and she was a mediator for the U.S. District Court for the District of Columbia and the D.C. Human Relations Commission. Before entering private practice, Ms. Lerner was law clerk to the Hon. Julian Abele Cook, Jr., Chief U. S. District Court Judge for the Eastern District of Michigan. She holds a J.D. from New York University (NYU) School of Law, where she was a Root-Tilden-Snow public interest scholar. She earned her undergraduate degree from the University of Michigan, with highest honors, and a diploma in General Studies from the London School of Economics. While an undergraduate, Ms. Lerner was a Harry S. Truman public interest Scholar and a James B. Angel Scholar.^[15]

• William E. Reukauf, Acting (Nov. 2008 - Apr. 2011). Mr. Reukauf joined the legal staff of the U.S. Office of Special Counsel (OSC) in January 1983. He was appointed Associate Special Counsel for Prosecution in February 1985. In 2001 he became the head of an Investigation and Prosecution division. Prior to taking over as Acting Special Counsel, he had responsibility for managing the activities of the agency’s regional field offices, as well as responsibility for OSC’s Alternative Dispute Resolution Program.^[16] Prior to joining OSC, Mr. Reukauf was, for several years, in private practice in Washington, DC. His practice was focused on general civil litigation and criminal defense. Mr. Reukauf began his legal career in 1970, as an Assistant United States Attorney for the District of Columbia. In 1973 he joined the General Counsel’s office of the U.S. Environmental Protection Agency, as a senior trial attorney where he prosecuted enforcement actions involving toxic chemicals in the Division of Pesticides & Toxic Substances. Mr. Reukauf received his undergraduate degree from Hamilton College in 1966 and his law degree from Georgetown University Law Center in 1969. He is the author of Regulation of Toxic Pesticides, 62 Iowa L. Rev. 909 (1976–1977).

• Scott J. Bloch (Dec. 2003-Nov. 2008). On June 26, 2003, President George W. Bush nominated Scott J. Bloch for the position of Special Counsel at the Office of Special Counsel. The U.S. Senate unanimously confirmed Mr. Bloch on December 9, 2003. On Jan. 5, 2004, he was sworn in to serve a five-year term. Mr. Bloch brought 17 years of experience to the Office of Special Counsel, including litigation of employment, lawyer ethics, and complex cases before state courts, federal courts and administrative tribunals. He briefed and argued cases before state and federal appellate courts. From 2001-2003, Mr. Bloch served as Associate Director and then Deputy Director and Counsel to the Task Force for Faith-based and Community Initiatives at the U.S. Department of Justice, where he worked on First Amendment cases, regulations, intergovernmental outreach, and programmatic initiatives. Before serving in the Justice Department, he was a partner with Stevens & Brand, LLP, of Lawrence, Kansas, where he practiced in the areas of civil rights law, employment law, and legal ethics. Mr. Bloch tried jury trials before state and federal courts, representing employees and employers in cases involving whistleblower and other retaliation claims, as well as civil rights claims. He worked on important cases that set precedents in the field of legal ethics, including a ground-breaking Texas case that changed the way plaintiffs’ lawyers handle mass tort cases. Mr. Bloch served as chair of his county Bar Ethics and Grievance Committee, investigating cases of alleged breaches by attorneys of ethics rules, and making recommendations to the state Supreme Court on disciplinary action. He also served on the state board of discipline, hearing testimony and legal arguments, and making findings on appropriate discipline of attorneys. For five years, he served as an Adjunct Professor at the University of Kansas School of Law. Mr. Bloch earned his bachelor's and law degree from the University of Kansas, where he graduated Order of the Coif, and served on the Boards of Editors of The Kansas Law Review and The Kansas Criminal Procedure Review. He lives with his wife, Catherine, and their seven children in Alexandria, Virginia.^[17]

• Elaine Kaplan (April 1998 – Dec. 2003). Ms. Kaplan came to OSC with extensive experience litigating employment-related issues before federal courts and administrative tribunals. Prior to her appointment as Special Counsel by President William Jefferson Clinton, Ms. Kaplan served as Deputy General Counsel of the National Treasury Employees Union (NTEU), where she represented the interests of 150,000 employees in the areas of civil liberties, administrative law, racial and sexual discrimination, and labor law. During her 13 years at NTEU, Ms. Kaplan briefed and argued dozens of cases at all levels of the federal courts on behalf of the union and the federal employees it represented. Many of the cases in which Ms. Kaplan participated resulted in important precedent-setting decisions including, among others, National Treasury Employees Union v. Von Raab, 489 U.S. 656 (1989) (the first Supreme Court decision addressing Fourth Amendment implications of urinalysis drug-testing in the public workforce) and National Treasury Employees Union v. United States, 115 S.Ct. 1003 (1995) (which struck down on First Amendment grounds the statutory “honoraria ban” as applied to federal employees). Ms. Kaplan began her legal career in 1979 at the U.S. Department of Labor, Office of the Solicitor, where she worked as a staff attorney in the Division of Employee Benefits. In 1982, Ms. Kaplan was selected to serve on the staff of the newly created Division of Special Appellate and Supreme Court Litigation, which was established to handle the Department’s most significant appellate cases and all of its Supreme Court work. She subsequently held the position of staff attorney at the State and Local Legal Center, where she drafted amicus briefs on behalf of state and local governments for submission to the United States Supreme Court. Ms. Kaplan, who is a native of Brooklyn, New York, received her undergraduate degree from Binghamton University and her law degree from the Georgetown University Law Center.^[18]

• William E. Reukauf, Acting (~1997-April 8, 1998)

• Kathleen Day Koch (Dec 20, 1991 – ~1997). Prior to appointment by President George Herbert Walker Bush, Ms. Koch previously held the position of General Counsel of the Federal Labor Relations Authority from December 1988 to December 1991. In her term as General Counsel, she encouraged a heightened emphasis on conflict resolution through cooperation and dispute avoidance. She has been instrumental in creating a conflict resolution seminar program that has been utilitized by various federal agencies nationwide. Ms. Koch’s entire legal career has been in public service, where she has developed expertise in federal employee and government ethics issues. Prior to he appointment to the FLRA, she served as Associate Counsel to the President. She was asked to join the White House staff while serving as Senior Attorney in the Personnel Law Division at the Commerce Department. During the significant formative period of the Merits Systems Protection Board (1979–1984), Ms. Koch participated in the development of the adjudicatory agency’s procedural and substantive precedents. Her government career began in 1977 when she was appointed an Honors Program attorney at the Department of Housing and Urban Development. A native of St. Louis, Missouri, Ms. Koch studied at Concordia College in Riverside, Illinois. She received her B.S. degree with honors from the University of Missouri at St. Louis in 1971, and was honored that year as a finalist in the Danforth Urban Leadership Fellow competition. Ms. Koch took her law degree from the University of Chicago, graduating in 1977.^[19]

• Mary F. Weiseman (Sept. 1986-1991). The third Special Counsel appointed by Ronald Reagan, Ms. Weiseman formerly served as Inspector General of the Small Business Administration. As Special Counsel, Wiseman focused on enforcement of the Hatch Act, which was then under review for statutory change, weakening its provisions. Wiseman’s goal was to vindicate the rights of government employees to be free from direct and indirect pressure by their supervisors to engage in partisan politics both on and off the job.^[20]

• Lynn R. Collins, Acting (June 1986-Sept. 1986). Had been the Deputy Special Counsel; in the next decade Collins would serve as Special Assistant to the Regional Solicitor, U.S. Department of Interior, Sacramento, California.

• K. William O’Connor (Oct. 1982 – June 1986 ). The second Special Counsel appointed by President Ronald Reagan, Mr. O'Conner formerly served as Inspector General of the Community Services Administration. Prior to 1981, O'Connor had served as Special Counsel for Interagency Coordination and Staff Director of the Executive Group Staff. His duties included advising the Deputy Attorney General on policy, programs, and matters affecting the Executive Group. In 1978-80 he was Senior Trial Attorney (Prosecutor/GSA Task Force) and led teams of investigators and lawyers in grand jury investigations of fraud schemes at the General Services Administration. In 1976-78 he was Associate Justice and then Chief Justice, High Court of American Samoa. Mr. O'Connor was vice president and counsel, Association of Motion Picture and Television Producers, Inc., in 1975-76; Special Counsel, Intelligence Coordination, Department of Justice, in 1975; Deputy Assistant Attorney General, Civil Rights Division, in 1971-75; Chief, Criminal Section, Civil Rights Division, in 1970-71; assistant to the Assistant Attorney General, Civil Rights Division, in 1967-70. Previously he held various positions with the Job Corps.^[21] Mr. O'Connor was graduated from the University of Virginia (B.A., 1952; LL.B., 1958). He served in the U.S. Marine Corps and was discharged in 1955 as first lieutenant.

• Alex Kozinski (June 5, 1981 – Aug. 1982). The first Special Counsel appointed by President Reagan, Kozinski formerly served as an attorney with the Office of Counsel to the President; previously practiced with Covington & Burling in Washington, D.C.

• Mary Eastwood, Acting (Jan. 11, 1980 – June 5, 1981). A native of Wisconsin, Mary Eastwood was graduated from the University of Wisconsin Law School in 1955 and moved to Washington, D.C., where she worked on a temporary study project for the National Academy of Sciences. She joined the Justice Department's Office of Legal Counsel in 1960, serving both as an attorney advisor and later (1969–1979) as an equal opportunity advisor. The following year Eastwood became the associate special counsel for investigation in the special counsel's office of the Merit System Protection Board, which was charged with looking into allegations of illegal personnel practices in the federal government. As technical secretary to the civil and political rights committee of President Kennedy's Commission on the Status of Women (PCSW), Eastwood researched decisions involving women and the Fourteenth Amendment, and became increasingly interested in the women's movement. With Pauli Murray she wrote the highly influential article "Jane Crow and the Law: Sex Discrimination and Title VII," which appeared in the Georgetown Law Review (34, December 1965). She was very active in the formation of the National Organization for Women (NOW); a board member of Human Rights for Women (HRW), an organization formed in 1968 to help finance sex discrimination litigation and research projects on women's issues; and a member of Federally Employed Women (FEW), a group that sought an end to sex discrimination in the federal government.^[22]

• H. Patrick Swygert ( Jan. 2, 1979 – Dec. 21, 1979). Mr. Swygert was a recess appointment by President James Earl Carter, under an Administration whose support for the mission of Office of Special Counsel has been critiqued as lacking.

Sources and notes

1. ^ Official OSC Web site main page.
2. ^ Tom Hamburger, "Inquiry of Rove Brings Unit Out of Obscurity", The Los Angeles Times April 24, 2007, rpt. in The Seattle Times, accessed April 26, 2007
3. ^ Office of the Inspector General, U.S. Department of Defense, Statement of Mr. Thomas F. Gimble Acting Inspector General Department of Defense before the Subcommittee on National Security, Emerging Threats, and International Relations House Committee on Government Reform on National Security Whistleblower Protection (Feb. 14, 2006) at 5.
4. ^ Louis Clark, Blowing the Whistle; the Consequences of Truth, The Case Against Corporate Crime (8:5)(May 1987).
5. ^ Tom Devine, Executive Director, Governmental Accountability Project, TESTIMONY OF THOMAS DEVINE,LEGAL DIRECTOR, GOVERNMENT ACCOUNTABILITY PROJECT before the SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT MANAGEMENT of the SENATE COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS on The Perils of Politics in Government: A Review of the Scope and Enforcement of the Hatch Act (Oct. 18, 2007).
6. ^ "Prohibited Personnel Practices", official OSC website.
7. ^ "Scott J. Bloch, Special Counsel", official OSC Web site.
8. ^ Schulman, Daniel (2007-04-24). "Office of Special Counsel's War On Whistleblowers". Mother Jones. http://www.motherjones.com/news/feature/2007/05/dont_whistle_while_you_work.html. Retrieved 2007-07-26. 
9. ^ FBI Raids Special Counsel Office, Seizes Records, NPR, 6 May 2008
10. ^ "Office of Special Counsel - the dark legacy", Red County, July 23, 2010
11. ^ Documents Concerning the Office of Special Counsel 2005, Project On Government Oversight (pogo.org).
12. ^ "Federal Whistleblower Office Faces Criticism", Andrea Seabrook, All Things Considered, March 9, 2005.
13. ^ "Akaka Chairs Oversight of Government Management Subcommittee hearing on 'Safeguarding the Merit System Principles'", March 22, 2007, akaka.senate.gov.
14. ^ Robert Brodsky, Office of Special Counsel finally has a new leader, Government Executive (Apr. 15, 2011).
15. ^ Carolyn N. Lerner, Heller, Huron, Chertkof, Lerner, Simon & Salzman (Apr. 19, 2011).
16. ^ http://www.osc.gov/Reukauf.htm
17. ^ U.S. Office of Special Counsel Fiscal Year 2003 Annual Report.
18. ^ A Report to Congress From The U.S. Office Of Special Counsel For Fiscal Year 2001.
19. ^ A Report to Congress From The U.S. Office Of Special Counsel For Fiscal Year 1992.
20. ^ Wayne King, Judge Rules Ohio Aides Coerced Subordinates for Political Funds, N.Y. Times (Oct. 29, 1987).
21. ^ http://www.presidency.ucsb.edu/ws/index.php?pid=43777
22. ^ http://oasis.lib.harvard.edu/oasis/deliver/~sch00563